Hi, I'm having trouble understanding the difference between Adickes and Celotex.

In Adickes, it was basically - "the facts you lay out don't directly suggest conspiracy," but the court ruled that an inference can be made and overruled the SJ.In Celotex, it was basically - "you don't have facts that suggest proximate cause," and the court granted SJ.

I feel like they're very similar. For example, saying "the facts you lay out don't directly suggest conspiracy" basically means "you don't have facts that suggest conspiracy." I have in my notes that Adickes is about negating an element essential to plaintiff's claim, whereas Celotex is about pointing out the absence of evidence supporting plaintiff's claim.

Those are as applied to the facts. The rule out of Adickes is that the movant carries the burden of proof to establish a lack of factual controversy. Celotex is defining the weight of the burden: Movant need only show that opposing party lacks evidence sufficient to support its claim. (We didn't spend much time on these two, but Wiki helped).

Thanks, that clarified it a bit. But another question: in Celotex, the inference that Celotex's asbestos caused the death was not allowed, whereas the inference that a conspiracy existed was allowed in Adickes. Is this due to a difference in judge/court (and I would explain it could go either way) or is there some rule explaining this?

I feel like in Adickes, the court could have easily ruled similar to Celotex and said defendant showed an absence of evidence going to essential element of claim.

perfunctory wrote:Thanks, that clarified it a bit. But another question: in Celotex, the inference that Celotex's asbestos caused the death was not allowed, whereas the inference that a conspiracy existed was allowed in Adickes. Is this due to a difference in judge/court (and I would explain it could go either way) or is there some rule explaining this?

I feel like in Adickes, the court could have easily ruled similar to Celotex and said defendant showed an absence of evidence going to essential element of claim.

I think it was because Celotex was one of many manufacturers who were named in the suit. Assuming all facts to be true (I think that's the standard) the evidence didn't show that specifically their materials caused the harm, and the inference could go between any one of the manufacturers. Whereas in Adickes, assuming the facts to be true, the inference could point only one way.

Also, don't be afraid to find contradictions in these cases. Adickes is a Warren Court decision, and Celotex (along with the Anderson and Matsushita) comes after Rehnquist and Scalia join. SCOTUS was in transition, and while none of the cases explicitly overrule Adickes, the standard changes.